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evidence. Fed. R. Evid. 401. Joint Exhibits 4-D and 5-E support
petitioner's testimony that she was a licensed talent agent and
that she offered her services as a talent agent. These facts are
relevant, and we overrule respondent's objection.
With respect to Joint Exhibit 10-J, which is an example of
the service petitioner used to find acting parts for her artists,
we sustain respondent's objection. The amount claimed by
petitioner for this service was allowed in the notice of
deficiency and is not in dispute. Therefore, this exhibit is not
relevant.
With respect to respondent's hearsay objections, we sustain
them. The Federal Rules of Evidence define hearsay as "a
statement, other than one made by the declarant while testifying
at the trial or hearing, offered in evidence to prove the truth
of the matter asserted." Fed. R. Evid. 801(c). Normally,
hearsay is excluded from evidence unless an exception to the
hearsay rule applies. Snyder v. Commissioner, 93 T.C. 529, 532
(1989). Joint Exhibits 7-G, 8-H, and 9-I are excerpts from
reference books and articles which were offered by petitioner to
show that her expenses were ordinary and necessary for personal
managers. Thus, these exhibits are hearsay.
An exception to the hearsay rule allows the introduction of
learned treatises in evidence when they have been established as
reliable authority by an expert witness at trial and have been
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